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How Will New Inspection Rules Affect US Poultry Plants?

Controversial new rules from the USDA to change the system of poultry meat inspection in the US came into effect on 20 October 2014.

The new regulations are aimed at placing more inspectors at the sharp end of detecting food safety issues rather than quality issues.

The concern from the USDA has been that there have been too many inspectors based on the line looking for blemishes in the poultry meat, broken legs and other quality issues rather than testing for pathogens and other food safety issues.

However, the regulations have caused an outcry from some sections of the public, in particular campaigning groups, who have described them as the privatisation of the inspection service, and they have even sparked industrial action amongst the poultry meat inspectors’ union.

Critics were concerned that by leaving more of the inspection responsibility to the poultry plants themselves it will reduce the effectiveness and objectivity of the inspections.

At the same time, the actual process of changing to the new rules raised questions about whether the change itself had caused a drop in the effectiveness of the entire USDA system.

The New Poultry Inspection System (NPIS) covers two main issues:

NPIS is designed for processing plants that slaughter young chickens and any that slaughter turkeys. Those plant can choose to follow new requirements, which are aimed at better control of Salmonella and Campylobacter. NPIS will not replace the current Streamlined Inspection System (SIS), the New Line Speed Inspection System (NELS) or the New Turkey Inspection System (NTIS). This means that young chicken and turkey slaughter plants can choose to operate under NPIS or continue to operate under their current inspection system. USDA does not put a limit on the number of inspectors who are on the line in traditional inspections but will continue to staff all establishments that do not choose to operate under NPIS with their current number of online inspectors.

The final rule also includes changes to the regulations that will apply to all establishments that slaughter poultry other than ratites. Under this final rule, all poultry slaughter establishments must develop, implement and maintain written procedures to ensure pathogen controls and testing requirements, and they must incorporate these procedures into their Hazard Analysis and Critical Control Points (HACCP) plans or Sanitation Standard Operating Procedures (SSOPs) or other prerequisite programs.

The new NPIS system actually reduces the number of USDA inspectors to two per line.

While reducing the number of agency personnel, NPIS is designed to make pathogen reduction in poultry products simpler by relying upon FSIS inspectors to perform more offline inspection activities at critical points where the agency feels are more effective in ensuring food safety where adulteration is most likely identified.

Dr Richard Raymond, the former USDA Undersecretary for Food Safety speaking at a seminar on pathogen reduction at last year’s International Production & Processing Expo said that the new rules will help improve food safety while at the same time saving money.

He said that typically, there had been four inspectors on the line looking at quality issues and just one at the end of the line is testing for food safety problems.

He said that the changes were expected to free up 1,500 inspectors to enable them to look for pathogens and other similar problems, while employees of the processing companies should be searching for quality defects.

The new proposals, however, had run into opposition from the unions because it was felt they would mean a potential loss of 800 positions.

But Dr Raymond said that new measures could save the US tax-payer up to $100 million over three years and prevent at least 5,000 foodborne illness cases a year.

Under the new regime, the sampling frequency is based on annual production volume and, except for very small or very low volume establishments operating under traditional inspection, all poultry slaughter establishments (other than those that slaughter ratites) must collect and analyse a pair of samples, one at pre-chill and one at post-chill. Very low volume and very small establishments operating under traditional inspection are required to test at post-chill only.

The frequency of sample collection is once per 22,000 carcasses but at a minimum of once during each week of operation and for turkeys, ducks, geese, guinea fowl and squabs, once every 3,000 carcasses but at a minimum of once during each week of operation

All young chicken and turkey slaughter plants have until 23 February 2015 to notify their District Office in writing of their intent to operate under the NPIS (79 FR 49566 and 49593). Establishments that do not notify their District office of their intent by 23 February will be deemed to have chosen to remain with their current inspection system.

The 20 young chicken and five turkey plants that took part in the HIMP pilot are expected to notify the authorities that they will be changing.

On 20 October 2014, the regulations that prescribe new requirements for online/offline reprocessing and chilling went into effect, and the generic E. coli regulations for all poultry except for ratites were rescinded.

This meant that all derogations for online/offline re-processing and alternative chilling procedures ended on 20 October and all plants that were using these technologies had to comply with the new regulations.

Under these new regulations, the plants’ chilling procedures or off-line reprocessing procedures have to be addressed in their HACCP plans, sanitation SOPs or other programmes.

All large establishments were required to meet the new regulations requiring that they maintain programmes to prevent faecal and enteric pathogen contamination throughout the slaughter operations by 19 November 2014.

When samples are collected, particularly in the pre-chill period of processing, the plants can decide for themselves where best to take the samples.

Pre-chill means any location from rehang to before the chiller.

For plants that are producing ready-to-cook (RTC) products, the veterinary inspector has to verify that the plant meets the RTC requirements through a records’ review. FSIS said that it intends to schedule this review routinely.

FSIS said that it is not setting numeric values associated with the observation of visible contamination in the production run.

It said that it will verify that the plants meet the requirements throughout the process and according to the plants’ plans, and it will verify the effectiveness of an establishment’s process control procedures in preventing carcasses from becoming contaminated with enteric pathogens and faecal material by reviewing the monitoring records, including the processing plants’ microbial testing results, observing that it is implementing its procedures, and inspecting carcasses and parts for visible faecal contamination when conducting both online carcass inspection and offline verification inspection procedures.

The inspection service said that it expects it will be summer 2015 before the agency will be able to convert establishments to operating under NPIS.

FSIS said that it had decided not to give plants the option to stagger implementation by line and shift because it felt it would be too difficult for FSIS to perform its inspection activities at establishments that are operating different lines or shifts under the NPIS and one of the other inspection systems at the same time.

For Agency planning and resource purposes, if an establishment wants to convert to the NPIS, all of the establishment’s lines and shifts will have to switch to the NPIS during the transition.

However, FSIS said that if a plant wants to make changes to its operation to prepare for conversion to the NPIS, FSIS will try and accommodate those changes as long as they do not affect FSIS inspection activities or procedures.